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When must a Casino file a Currency Transaction Report (CTRC)?
Question: When must a Casino file a Currency Transaction Report (CTRC)?
Answer: In an effort to prevent and detect money laundering and other financial crimes, the Bank Secrecy Act (BSA) requires that casinos and card clubs report transactions in currency involving cash-in or cash-out of more than $10,000 using FinCEN Form 103 Currency Transaction Report (CTRC).
Reportable transactions in currency involving cash-in include, but are not limited to:
- Purchases of chips, tokens and other gaming instruments.
- Front money deposits.
- Safekeeping deposits.
- Payments on any form of credit, including markers and counter checks.
- Bets of currency.
- Currency received by a casino for transmittal of funds through wire transfer for a customer.
- Purchases of a casino's check.
- Exchanges of currency for currency, including foreign currency.
Reportable transactions in currency involving cash-out include, but are not limited to:
- Redemptions of chips, tokens, and other gaming instruments.
- Front money withdrawals.
- Safekeeping withdrawals.
- Advances on any form of credit, including markers and counter checks.
- Payments on bets, including slot jackpots.
- Payments by a casino to a customer based on receipt of funds through wire transfer for credit to a customer.
- Cashing of checks or other negotiable instruments h. Exchanges of currency for currency, including foreign currency.
- Reimbursements for customers' travel and entertainment expenses by the casino.
- Payment for tournament, contest or other promotions.
Casinos must complete and submit a CTRC within 15 days following the day the reportable transaction occurs. Copies of all filed CTRCs, must be retained by the casino for five years from the date of the report. Casinos should ensure that all employees are properly trained to comply with the Bank Secrecy Act to know when to file a CTRC.
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First published on BankersOnline.com 2/18/08
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